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Introduction
Gibraltar is an attractive location to establish an insurance company and offers the potential to passport into the UK. Gibraltar is also a well-respected jurisdiction with the potential for innovative solutions such as through use of the Protected Cell Company legislation.
Gibraltar has a dynamic and collaborative approach to regulation and may offer cost advantages. In order to be authorised, the Financial Services Commission (FSC) have set out a Pre-Application Process and Staged Application Approach, which came into effect in 2024.
In addition to the above attributes, the ease of setting up a new business in Gibraltar is aided by the mature insurance industry with a proven model whereby new entrants often work with Insurance Manager(s) who guide them through the authorisation process and also provide critical outsource functions upon authorisation.
Gibraltar licensees collectively account for significant proportions of the UK market across motor (30%), pet (20%), and travel insurance (30%).
Pre-application process
The pre-application process has been designed by the FSC, to help applicants understand the authorisation approach and to provide an opportunity to discuss the proposed business model.
Use of the pre-application process is strongly recommended by the FSC, they note an increase in the quality of applications submitted from those applicants who have used the pre-application process in comparison to those who have not.
Following an initial introductory meeting, an abridged business plan is submitted. The FSC then provide their feedback during a second meeting. This meeting should take place within 4 weeks of the FSC receiving the applicant’s business plan. In addition to the meetings, the FSC have developed a checklist for the Abridged Business Plan for Insurance Companies.
Staged approach
The FSC introduced the Staged Application Process in early 2024. The purpose of this process was to produce a streamlined framework for the authorisation of firms that is sector-specific and subject to a time frame.
The intention of the process is to allow the application of a risk-based approach by the Regulator. Applying a risk-based approach allows the FSC to both meet its regulatory objectives and accelerate time to market.
Gibraltar licensees collectively account for significant proportions of the UK market across motor, pet, and travel insurance.
Process overview
The application for authorisation process has been divided into three stages. Applicants must successfully complete each stage in sequence. Within the Insurance sector, applicants can expect to move through the first three stages within a maximum period of 9 months.
The time taken to process an application depends on the quality and extent of information provided by the applicant, as well as the timeliness of the submission. However, the FSC may determine an incomplete application if it considers it appropriate to do so, and this must be determined within 12 months of initial submission.
| Stage * | Area | Duration ** | GFSC Documentation Requirements |
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Stage 1
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5 months
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Stage 2
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2 months
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Stage 3
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2 months
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*The Staged Application Approach also includes a Stage 4 mobilization phase. This is not applicable to the Insurance Sector.
**Expected maximum period is subject to the quality of information submitted and timely responses from the applicant.
Our team’s selected experience
Grant Thornton’s team has extensive experience across a wide range of jurisdictions.
We have included some credentials below that highlight the ability of GT to deliver an independent, high-quality service.
Assisted the Financial Services Commission in conducting due diligence on an application for a new life insurance entity.
This included assessing the completeness of the documents required for the application, reviewing the business model, conducting various risk assessments, reviewing capital adequacy , checking the efficiency of the proposed systems, processes and controls and highlighting the areas of key risks to the regulator.
Our actuarial team provides support for the statutory audit of a number of insurance companies based in Gibraltar and globally.
The reviews cover the processes and controls applying to the valuation of liabilities, the production of best estimates and Solvency II figures including key components of the SCR. Our team regularly recalculates key items of our clients’ figures under review to confirm their accuracy, including data and model reviews where required.
Our Insurance Team has supported a number of insurers with reviews to support them in preparing for regulatory inspections or with addressing any findings resulting from a regulatory review.
These reviews are adaptable to the needs to each business and the subject matter of the inspection/finding. They can range from more informal support to high level red flag reviews to more in-depth independent assurance reports to the Board. We engage our subject matter experts as needed to support on these reviews.
Grant Thornton provided project management and delivery expertise to support a market leading Irish Insurance company in co-ordinating and implementing the appropriate measures in line with the Operational Resilience Guidelines published by the Irish regulator.
This included identifying and assessing the company’s Critical or Important Business Services (CIBS), comprehensive mapping of the chain of activities that contributed to the delivery of each CIBS and, creation of an Operational Resilience Framework. In addition, Impact Tolerances for CIBS alongside a Scenario Testing Plan were created.
Authors
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Bradley Chadwick Bradley leads the Grant Thornton Gibraltar advisory practice, where he leverages his experience as an advisor, CFO, COO and interim manager to support clients with strategic, regulatory, transactional and restructuring matters.View Profile -
Nuala Crimmins Nuala joined the firm as a Partner in 2021 and is Head of Insurance for Grant Thornton Ireland. She heads up the firms Insurance offering.View Profile